NH: Protective sweep of motel room search justified by presence of others

A protective sweep of defendant’s motel room on his arrest was justified by the fact he was suspected of selling crack out of it and there were three woman also there, one of whom turned her back on the officers when they came in. State v. Minson, 2020 N.H. LEXIS 141 (Aug. 18, 2020).

Defendant was in a car at a Jack in the Box drive-thru in the early morning hours. A store employee called the police because the occupants were laughing and said they had alcohol in the car when he said it would take 10-15 minutes for their order. He encountered them and saw 32-ounce beer cans in the car. This added up to reasonable suspicion. State v. Wilson, 2020 Ida. App. LEXIS 64 (Aug. 20, 2020).* [This was just too thin for reasonable suspicion for me.]

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